Questions that auditors may want to ask: Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review

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1 Audit Criteria 4.1 General Requirements 14001:2004 The organization shall establish, implement, maintain, and continually improve an environmental management system in accordance with the provisions of ISO (e 2004 or most current) and determine how it will fulfill those requirements. The organization shall define and document the scope of its environmental management system. Army EMS Policy: Army policy requires appropriate facilities will implement an installation wide EMS that is inclusive of all installation mission, sub-installations, facilities (including GOCO), tenants, contractors, activities, products and services. If the installation determines that its environmental responsibilities or liabilities are limited for nongovernmental tenants leasing space, they may choose to exempt them from its EMS. AR 200-1, 1 1. Purpose b. This regulation defines the framework for the Army Environmental Management System (EMS). All appropriate facilities were to have implemented a mission focused EMS by the end of calendar year (CY) 05, and must attain International Organization for Standardization standard (ISO 14001) conformance by the end of FY09. [FY09 changed to CY09 by DASA ESOH] Questions that auditors may want to ask: Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review Has the installation documented the scope of its EMS? Is it consistently defined within related EMS documentation? Does the scope include all mission, subinstallation, facilities, tenants, contractors, activities products and services? If not, is there documented rationale for not including? If tenants are not included currently is there a plan in place to include those that contribute to significant aspects? Is there evidence that the installation has implemented, maintained, and improved the system? 9/21/2010` Page 1 of 45

2 Audit Criteria 4.2 ENVIRONMENTAL POLICY 14001:2004 ISO 4.2 Environmental Policy U.S. Army-Hawaii Sustainable Environmental Management Top management shall define the organization s environmental policy and ensure that, within the defined scope of its environmental management system, it: (a) is appropriate to the nature, scale and environmental impacts of its activities, products or services; (b) includes a commitment to continual improvement and prevention of pollution; (c) includes a commitment to comply with applicable legal requirements and with other requirements to which the organization subscribes which relates to its environmental aspects; (d) provides the framework for setting and reviewing and environmental objectives and targets; (e) is documented, implemented and maintained; (f) is communicated to all persons working for or on behalf of the organization, and (g) is available to the public. Questions that auditors may want to ask Person/Position Requirements Reference Results Comments/Interviewee Garrison What are some of the key requirements of the Commander installation s environmental policy? How has the policy improved environmental performance? How often do you review the policy? How do you engage tenants and ensure that they participate in the EMS? How effective do you think the policy is communicated to the Soldiers/workforce? How is the policy re-enforced? EMS Does the organization have an environmental MR/Document policy that is relevant to its activities? review Does the policy reflect the organization s scope and mission? Has top management (Garrison Cmdr) approved or signed the environmental policy and has someone (MR) been identified and given the authority to oversee and implement the policy? Does the policy guide the setting and reviewing of 9/21/2010` Page 2 of 45

3 Public Affairs All others environment objectives and targets? What commitments are embodied in the environmental policy (for example, support for continual improvement, support for the prevention of pollution, monitoring, meeting or exceeding legal requirements, and consideration of the expectations of interested parties)? How has the facility distributed the environmental policy to all employees? Does the environmental policy address the facility s commitment to federal, state, and local laws? Does the environmental policy address continual improvement? How does the installation make the environmental policy available to the public? How is the policy communicated to the public? How is PAO involved with communicating the policy to the workforce? Are you familiar with the environmental Policy? Have you seen a copy of it? What is the command emphasizing in the policy (Compliance, prevent pollution, continual improvement)? 9/21/2010` Page 3 of 45

4 Audit Criteria ENVIRONMENTAL ASPECTS 14001:2004 The organization shall establish, implement, and maintain a procedure(s) (a) to identify the environmental aspects of its activities, products, and services within the defined scope of the environmental management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and (b) To determine those aspects that have or can have significant impacts on the environment (i.e. significant environmental aspects). The organization shall keep this information up-to-date. The organization shall ensure that the significant environmental aspects are taken into account in establishing, implementing and maintaining its environmental management system. Federal EMS Metric: Annually review previously identified significant aspects; re-evaluate them and update as necessary in accordance with ISO 14001, Environmental Aspects, and the installation s EMS aspects procedure. Questions that auditors may want to ask. Person/Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review What are the environmental aspects of the organization s activities, products and services? Do the organization s activities, products or services create any significant adverse environmental impacts? How are the environmental aspects documented and kept up to date? Does the procedure require an annual review and update of the aspects? Does the organization have an implemented procedure for evaluating the environmental impacts of new projects? Does the location of the organization require special environmental consideration, for example sensitive environmental areas? Does local community concerns warrant special consideration for certain activities (noise or other issues) How will any intended changes or additions to 9/21/2010` Page 4 of 45

5 Garrison Commander/Other Senior Leaders activities, products or services affect the environmental aspects and their associated impacts? Have the cumulative effects of smaller activities been taken into account? What criteria are used to determine significance? Are legal requirements and mission impacts taken into account? Has the organization documented the results of the initial review of environmental aspects? Is procurement of new materials, subcontracting, notified of the significant aspects? How are they communicated to suppliers/contractors? How has future strategic planning initiatives been include in the identified environmental aspects? Have activities related to BRAC been included? Is there a system in place for modifying, if necessary, the environmental policy and the objectives and targets, based on new data derived from the environmental aspects review? How are the significant aspects taken into account when setting objectives and targets? How are aspects taken into account in development of operational controls? What are some of the top environmental Concerns (significant aspects) that the command is focusing on? How are these communicated to the workforce? What if anything do you feel warrants further consideration? How involved are you in determining significant environmental aspects? How has this risk based approach helped the installation deal with environmental risk? How does the command ensure that proper resources are put towards these significant environmental issues? 9/21/2010` Page 5 of 45

6 Workers whose job could cause significant impact General Workforce What environmental issues/concerns is the command emphasizing? How do they relate to your job? (go to training section) What environmental issues/concerns is the command emphasizing? 9/21/2010` Page 6 of 45

7 Audit Criteria LEGAL AND OTHER REQUIREMENTS 14001:2004 The organization shall establish, implement, and maintain a procedure(s) (a) to identify and have access to the applicable legal requirements, and other requirements to which the organization subscribers related to its environmental aspects, and (b) to determine how these requirements apply to its environmental aspects. The organization shall ensure that these applicable legal requirements and other requirements to which the organization subscribes are taken into account in establishing, implementing, and maintaining its environmental management system. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document How does the organization access and identify Review relevant legal and other requirements? Has the facility developed a procedure to identify, and have access to legal requirements of the facility s activities, products and services? How does the organization keep track of legal and other requirements? Does the facility use any of the following information sources to double-check legal requirements? Federal Register? State Register? Initial environmental review information? REO newsletters? Results of previous compliance audits? Information clearinghouses? SJA? How does the organization communicate relevant information on legal and other requirements to employees? Is there a system in place to evaluate the legal requirements of any new activities, products and services? How have NEPA mitigation activities been addressed? 9/21/2010` Page 7 of 45

8 Have any agreements with public authorities been signed upon that have an affect on the environmental impact of the facility s processes? (consent agreements?) How are legal requirements taken into account when determining aspects? Environmental Program Managers SJA What environmental permits and permitting agencies is the facility subject to? What permit reports are submitted; at what frequency? How do you ensure that you identify any new or changed environmental laws/regulations? (does this match the installations procedure?) How are you informed of new activities/products or services on the installation? How do you evaluate that activity/product or service to determine applicable requirements? How do you ensure that workers understand regulatory issues with their job (See operational controls)? What is your role in the EMS? How do you participate in the legal/other requirements piece of the EMS? How are you informed of new activities/products or services on the installation? How are NEPA Mitigation requirements incorporated into the EMS? Who checks to see if they have been completed? 9/21/2010` Page 8 of 45

9 Audit Criteria OBJECTIVES, TARGETS AND PROGRAMS 14001:2004 The organization shall establish, implement, and maintain documented environmental objectives and targets, at relevant functions and levels within the organization. The objectives and targets shall be measurable, where practicable, and consistent with the environmental policy, including the commitments to prevention of pollution, to compliance with applicable legal requirements and with other requirements to which the organization subscribes, and to continual improvement. When establishing and reviewing its objectives and targets, an organization shall take into account the legal requirements and other requirements to which the organization subscribes, and its significant environmental aspects. It shall also consider its technological options, ifs financial, operational and business requirements, and the views of interested parties. The organization shall establish, implement and maintain a program (s) for achieving its objectives and targets. Program (s) shall include (a) designation of responsibility for achieving objectives and targets at relevant functions and levels of the organization, and (b) the means and time-frame by which they are to be achieved. Federal Metric: Establish, implement and maintain measurable, mission-focused objectives, targets and programs; review them annually; and update as appropriate, in accordance with ISO 14001, Objectives, Targets and Programs. AR Environmental objectives and targets b. Installations/activities will establish and maintain environmental objectives and targets for all operations and activities having the potential for important mission and/or environmental impact. Objectives and targets will be established at each relevant function and level within the organization, will be documented, and will meet DOD Measures of Merit (MOMs), Army-level program goals, objectives, and targets; long-term strategic goals; legal and other requirements; important environmental aspects; technological options; financial and operational requirements; and the views of interested parties, as appropriate. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review How do environmental objectives and targets reflect both environmental policy and significant environmental impacts? How are objectives and targets documented? What evidence exists that top management supports and approves of objectives and targets? How have objectives and targets been integrated 9/21/2010` Page 9 of 45

10 with installation s sustainability goals or the strategic plan? How have legal and other requirements been incorporated into the objectives and targets? How have the views of interested parties been considered? What specific measurable indicators have been established for objectives and targets? How are objectives and targets regularly reviewed and revised to reflect desired improvements in environmental performance? Is there a system in place to annually review and revise the objectives and targets? How have mission needs been taken into account in the development of objectives and targets? Have personnel been designated as responsible for objectives and targets? Are responsibilities shared at relevant levels/functions to ensure objectives are met? Are responsibilities outside of the environmental shop? Should they be? Has the facility established quantitative environmental objectives and targets? Is there a program to achieve objectives and targets which designates the means and time-frame? Have performance indicators been identified for objectives and targets? How does the installation measure performance? Is it adequate to ensure progress is being made? Does the organization have a structure of communication that will ensure that key contributors/organizations are aware of the facility s objectives and targets? How do the environmental objectives and targets show a commitment to continual environmental improvement? 9/21/2010` Page 10 of 45

11 Garrison Commander/Other Senior Leadership How do the programs address the issues of resources, responsibility, timing and priority? Does the environmental management planning process involve all responsible parties? How are requirements (as related to the O & T and programs) communicated throughout the organization? Is there a process for periodic reviews of the program? What is the forum used to communicate success/failure to senior management? What evidence exists that supports/refutes that they are on track to meet objectives? Is there any evidence of program reviews? Does it include a provision for review and assessment, after the program has been completed? Does the facility have funds programmed/committed to accomplish environmental objectives and targets? Are the objectives and targets achievable and measurable? Provide specific examples Are there Objectives and targets that are not related to significant aspects? What are they? What are some of the key objectives that you want the EMS to address and improve performance on? What forum is used to review objectives and targets? How often does this occur? What, if any, actions have you taken to ensure progress is being made on the objectives and targets? Have you seen improvement in the environmental program that can be attributed to the establishment of the EMS? What other objectives/targets do you see in the near future? What areas most concern you as a senior leader? 9/21/2010` Page 11 of 45

12 Program Managers/CFT Members or individuals assigned tasks under a program Workers whose job may be impacted by Objectives and targets. How have the employees responsible for achieving the objectives and targets had input into their development? Do they understand that they are responsible for achieving them? What specific measurable indicators have been established for objectives and targets? How are objectives and targets regularly reviewed and revised to reflect desired improvements in environmental performance? If a plan has been developed to achieve objectives and targets is it detailed enough to achieve stated goals? Does the plan identify specific action steps, schedules, resources, and responsibilities? What SOPS or operational controls have been established to ensure that workers understand what they need to do to minimize potential deviation from the objectives/targets? Do you know if the installation is trying to reduce XYZ? How is your job effected by that? What if anything have you had to change to help meet these goals? (see Operational Control) 9/21/2010` Page 12 of 45

13 Audit Criteria RESOURCES, ROLES, RESPONSIBILITY AND AUTHORITY 14001:2004 Management shall ensure the availability of resources essential to establish, implement, maintain and improve the environmental management system. Resources include human resources and specialized skills, operational infrastructure, technology and financial resources. Roles, responsibilities and authorities shall be defined, documented and communicated in order to facilitate effective environmental management. The organization s top management shall appoint a specific management representative(s) who, irrespective of other responsibilities, shall have defined rolls, responsibilities and authority for: (a) ensuring that environmental management system requirements are established, implemented and maintained in accordance with the requirements of this International Standard; (b) reporting to top management on the performance of the environmental management system for review, including recommendations for improvement. AR Senior mission commanders Senior mission commanders (SMC) will b. Participate in the installation s planning, sustainability efforts, and EMS Garrison commanders r. Implement and maintain a mission-focused EMS in accordance with the ISO standard. s. Champion the installation EMS and designate an EMS representative in the appropriate organizational planning cell; ensure all planning incorporates the requirements of the EMS Tenants c. Participate in the installation s planning, sustainability, and EMS (note, however, that installations should evaluate their liabilities concerning nongovernmental tenants to determine whether any of them can be exempted from the installation EMS) Commanders of Government-Owned, Contractor-Operated facilities f. Execute EMS responsibilities in accordance with contract provisions Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document How does the organization identify and allocate Review the human, technical and financial resources necessary to meet its environmental objectives and targets, including those for new projects? How does the organization track the costs and 9/21/2010` Page 13 of 45

14 benefits of environmental activities? What evidence is provided that shows management is providing the necessary resources/support for the programs established to achieve the objectives and targets? What are the responsibilities and accountability of personnel, who manage, perform and verify work affecting the environment, and are these defined and documented? What is the relationship between environmental responsibility and individual performance and is this periodically reviewed (tapes/nsps objectives)? Have the roles and responsibilities been documented for the people who will help form and implement the ISO EMS? Is there evidence that senior leadership Garrison Commander, directors, etc. -establish overall direction and support the EMS Policy and Objectives and targets; Has an EMSMR been designated? At what level does this person exist? Is that person at a sufficient level to promote and integrate EMS throughout the installation? Has a person been assigned the day-to-day management functions? How was the ISO Environmental Management Representative (EMR) appointment communicated to all employees? Is there a cross functional team? Is it active? What roles and responsibilities are associated with it? What functions/roles have been defined within the U.S. Army-Hawaii Sustainable Environmental Management 9/21/2010` Page 14 of 45

15 Garrison Commander/other Senior Leadership Program Managers All others EMS? Are they active participants? Does the EMR have the authority to implement and maintain the environmental management system? How does the installation senior leadership see EMS being used? What do you hope to accomplish with through the EMS? How do you see your role in the EMS? If the EMS MR is having difficulties getting things accomplished or garnering support across the installation how do you help facilitate discussions or move things forward? Has the risk based approach helped prioritized funding needs? Has management provided adequate resources to implement the EMS? Does this include human, technology, and financial resources? How has leadership supported the EMS? Are adequate resources (including people) made available to achieve the objectives and targets? Are people generally aware of what role/responsibility that you have for managing a program under the EMS? How has this been communicated? How do you ensure that people that perform tasks critical to you program are made aware of their responsibilities? If you are having trouble with a program who do you go to for help/support? Are these issues resolved in a timely manner? How do you see your role in the EMS? What specific responsibilities have you been assigned? 9/21/2010` Page 15 of 45

16 Audit Criteria COMPETENCE, TRAINING AND AWARENESS 14001:2004 The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. The organization shall identify training needs associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records. The organization shall establish, implement and maintain a procedure(s) to make persons working for it or on its behalf aware of : (a) the important of conformance with the environmental policy and procedures and with the requirements of the environmental management system, (b) the significant environmental aspects and related actual or potential impacts associated with their work, and the environmental benefits of improved personal performance, (c) their roles and responsibilities in achieving conformance with the requirements of the environmental management systems, and (d) the potential consequences of departure from specific procedures. Army Metric Memorandum from COL Schuster, Director Environmental Programs, 18 Jan 2005 The installation must establish a documented procedure and followed it to ensure that appropriate installation personnel have received ESM awareness training. Federal Metric: Establish, implement and maintain a procedure to identify training requirements and provide competence training to those individuals performing tasks for, or on behalf of, the installation that have the potential to cause a significant environmental impact and retain all associated training records. Training will be developed in accordance with ISO 14001, Competence, Training and Awareness and the installation s training procedure. AR Commanders of Government-Owned, Contractor-Operated facilities h. Ensure that all contractor personnel receive appropriate levels of training on environmental awareness, hazardous material/waste management, and the installation EMS. EO (2) Tenant, contractor, and concessionaire activities. Where tenant, contractor, and concessionaire activities affect an agency s environmental, transportation, or energy issues, those activities shall be addressed in the development, implementation, and maintenance of the EMS. Requirements shall be included in all appropriate contracts to ensure that the contractors roles and responsibilities under the EMS are properly addressed. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review Is there a documented procedure for conducting awareness training? What are some of the mechanisms for ensuring awareness training reaches the intended audience? 9/21/2010` Page 16 of 45

17 How has top management established, reinforced and communicated organizational commitment to the environmental policy? How does the installation identify competence training needs? How are the training needs of specific job functions analyzed? Is training developed and reviewed and modified as needed? How is the training documented and tracked? Is there a system in place for ensuring that all workers, including new ones, who may have a significant environmental impact are adequately trained? Does the training program include the following areas: The importance of conforming to environmental policy and procedures? The importance of conforming to the EMS requirements? The significant environmental impacts, actual or potential, represented by trainees jobs? Employees role and responsibilities in conforming with the environmental policy and to the EMS requirements? If housing areas contribute to a significant aspect, how are personnel in housing trained? (recycling goals, prohibited disposal, etc) How do you ensure contractors and subcontractors are properly trained in environmental areas? How does the installation ensure that training continues to reflect changing data, policies, and objectives and targets or regulations? Are there implemented procedures for identifying the training needs of appropriate personnel? Are there training records for personnel with U.S. Army-Hawaii Sustainable Environmental Management 9/21/2010` Page 17 of 45

18 Environmental Program Managers/ Cross Functional Team Members PAO Shop Personnel General Population specific environmental tasks/qualifications? Internal Environmental Auditors Specially trained personnel Environmental testing personnel Environmental operations personnel, as appropriate. What training are you required to take in order to conduct your job? How do you know that employees who s work may contribute towards a significant aspect are properly trained? What role do you play in that training? Who maintains training records? What role do you play in the general awareness training at the installation? Have you had it? What are some of the Key environmental issues that the garrison is trying to manage? Have you written any articles for the local paper that supports the EMS? If so can we get a copy? What are the key environmental issues (significant aspects) that the command is emphasizing? How does your job relate to them? How do you know what training that you are required to take? What SOPs do you need to know for performing your job? How have you been trained on the requirement in the SOPs? How often are you required to review or train on SOPs? How do you ensure that new employees are trained prior to commencing work? Are you familiar with the environmental policy? What are some key messages or requirements outlined in the policy? 9/21/2010` Page 18 of 45

19 Audit Criteria COMMUNICATION 14001:2004 With regard to its environmental aspects and environmental management system, the organization shall establish, implement and maintain procedures for: (a) internal communication among the various levels and functions of the organization, (b) receiving, documenting and responding to relevant communication from external interested parties. The organization shall decide whether to communicate externally about its significant environmental aspects, and shall document its decision. If the decision is to communicate, the organization shall establish and implement a method(s) for this external communication. Questions that auditors may want to ask. Requirements Reference Results Comments/Interviewee EMSMR/Document What is the process for communicating the Review organization s environmental policy and performance? Is it clear how information is communicated across the different functions and levels within the organization? Does this communication strategy appear to be effective? What evidence exists to support this conclusion? Are your internal environmental communications used to: Demonstrate management commitment to the environmental policy and objectives? Answer questions and concerns about the facility s activities, products, and services, and their environmental impacts? Increase awareness internally about the organization s policy, objectives, targets and programs? Identify roles responsibilities and authorities of key staff members? Is internal communication adequate to support continual improvement around environmental issues? Communicate environmental performance data to 9/21/2010` Page 19 of 45

20 Public Affairs Env. Program Managers/Cross Functional Team Fire Department internal whenever appropriate? How are results of EMS/compliance audits and reviews communicated to effected organizations? Have you considered voluntary reporting of environmental management and performance information to the general public? Have you recorded the decision on this matter? Is a system in place, including delineated roles and responsibilities, for responding to relevant communication from outside interested parties? What is the process for receiving and considering the concerns of other interested parties? What other means are used to communicate internally or externally about the EMS? New articles? Press releases? Have you receive any communications on environmental issues from external parties recently? How is the environmental policy communicated to the public (outside of the installation)? Has anyone asked about it? How are changes communicated across the organization? What procedures are in place to ensure that the right people are notified if an organization changes a processes or adds to current capacity that has the potential to result in significant impacts? What are the potential communication breakdown points? Have there been instances where you were notified of changes, or were failed to be notified? Has emergency planning been initiated and communicated to public authorities? Is there a mutual aid agreement in place? 9/21/2010` Page 20 of 45

21 Audit Criteria DOCUMENTATION 14001:2004 U.S. Army-Hawaii Sustainable Environmental Management The environmental management system shall include: (a) the environmental policy objectives and targets, (b) description of the scope of the environmental management system (c) description of the main elements of the environmental management system and their interaction, and reference to related documents, (d) documents, including records, required by this International Standard, and (e) documents, including records, determined by the organization to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environmental aspects. AR Environmental Management System documentation and document control a. Installations will establish and maintain information in paper or electronic form to describe the core elements of the management system and their interaction, and provide direction to related documentation. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review How are environmental management procedures identified, documented, communicated and revised? Does the organization have a process for developing and maintaining EMS documentation? Are the environmental policy, objectives and targets documented in the EMS? How do employees access EMS documentation needed to conduct their job activities? In what form does the facility document its environmental management system? Does the documentation include a scope of the EMS? Is the scope consistent throughout all procedures and related documents? How does the facility document the main elements of an EMS, their interaction, and reference to related documents (EMS manual)? Where does the facility document its internal 9/21/2010` Page 21 of 45

22 environmental standards and operation procedures? Does the facility have documents concerning planning, operation and control of processes that relate to its significant environmental aspects? Have procedures been established that provide direction on where to obtain information on the operation of specific parts of the EMS? Does the facility integrate EMS documentation with documentation of other systems the facility has implemented? U.S. Army-Hawaii Sustainable Environmental Management 9/21/2010` Page 22 of 45

23 Audit Criteria CONTROL OF DOCUMENT 14001:2004 Documents required by the environmental management system and by this International Standard shall be controlled. Records are a special type of document and shall be controlled in accordance with the requirements given in The organization shall establish, implement and maintain a procedure to: (a) approve documents for adequacy prior to use, (b) review and update as necessary and re-approve documents, (c) ensure that changes and the current revision status of documents are identified, (d) ensure that relevant versions of applicable documents are available at points of use, (e) ensure that documents remain legible and readily identifiable, (f) ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the environmental management system are identified and their distribution controlled, and (g) prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose. AR Environmental Management System documentation and document control b. Installations will establish and maintain procedures for controlling all documents required by the ISO standard to ensure that: they can be located; they are periodically reviewed, revised as necessary, and approved for adequacy by authorized personnel; the current versions of relevant documents are available at all locations where operations essential to the effective functioning of the EMS are performed; obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured against unintended use; and any obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified. c. Documentation will be legible, dated (with dates of revision), and readily identifiable, maintained in an orderly manner and retained for a specific period. Procedures and responsibilities will be established and maintained concerning the creation and modification of the various types of documents. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review Are procedures established and implemented to approve documents before use? How are documents identified as needing to be controlled? What are mechanisms used to communicate changes to controlled documents? Has the facility made sure to establish and 9/21/2010` Page 23 of 45

24 implement procedures for controlling all documents required by ISO so that: They are periodically reviewed and revised as necessary, and approved for adequacy by authorized people? The current versions of relevant documents are available at all locations where relevant EMS functions are performed? (version number apparent?) Obsolete documents are promptly removed? Any obsolete documents kept for legal or other purposes are labeled or marked accordingly? Have procedures been established to identify external environmental documents and their distribution controlled? How does the installation know what documents must be controlled? Is there a master list of documents or equivalent document control procedure identifying current revision status? How is it updated? Are there procedures that address: Review Approval Issue Placement Amendments/Changes Removal How do they know who has a controlled document? Is there a distribution list? Who is authorized to: Create documents? Review documents? Authorize documents? U.S. Army-Hawaii Sustainable Environmental Management Env Program Managers/Cross What documents are critical to the proper functioning of this program? 9/21/2010` Page 24 of 45

25 Functional Team Shop level How are controlled documents identified? How are users notified of changes or new revisions? Can you provide a list of where controlled documents should be? How is the EMSMR or Env program managers notified of changes to process or procedures that may require environmental review? What SOPs or other plans are required to perform your job? How do you know that this is the most recent version? If your process changes, what do you do to notify the environmental division of changes? If you notice discrepancy between documents or procedures, who do you notify? 9/21/2010` Page 25 of 45

26 Audit Criteria OPERATIONAL CONTROL 14001:2004 The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions, by, (a) establishing and implementing and maintaining a documented procedure(s) to control situations where their absence could lead to deviations from the environmental policy and the objectives and targets, (b) stipulating the operating criteria in the procedures, and (c) establishing, implementing and maintaining procedures related to the identified significant environmental aspects of goods and services used by the organization and communicating on the relevant procedures and requirements to suppliers, including contractors. Federal Metric(s) Establish, implement and maintain documented operational controls in accordance with ISO 14001, Operational Controls to address significant aspects consistent with the installation s environmental policy and objectives and targets. Review them annually and update as appropriate. Establish a procedure to identify appropriate contracts and integrate EMS requirements in accordance with ISO 14001, Operational Control. Contracts will stipulate defined EMS roles and responsibilities of contractors, suppliers and tenants. Verify that contractors, suppliers and tenants are fulfilling their defined roles and responsibilities. For purposes of this metric, contracts include Installation Support Agreements with tenants. EO (2) Tenant, contractor, and concessionaire activities. Where tenant, contractor, and concessionaire activities affect an agency s environmental, transportation, or energy issues, those activities shall be addressed in the development, implementation, and maintenance of the EMS. Requirements shall be included in all appropriate contracts to ensure that the contractors roles and responsibilities under the EMS are properly addressed. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review Does the facility have a procedure to identify and plan operations that are associated with significant aspects consistent with its environmental policy, objectives and targets? Does the facility have documented operating procedures for activities, products, and services that have significant environmental impacts? How often are operational controls review? Has the facility documented SOPs where their absence could lead to deviation from the environmental policy (compliance) and objectives 9/21/2010` Page 26 of 45

27 Contracting and targets? Are these environmental control procedures aligned with the other organizational procedures such as operational parameters, safety and occupational health? Have all functions, activities, and processes been identified that have significant environmental impact? Have operational controls been identified for all of those instances? Do these procedures cover, for example: Raw material purchasing, storage, and use, where misuse could violate the environmental policy and objectives? Hazardous waste generation, storage, handling? Wastewater treatment, discharge? Air pollutant emissions, treatment, reduction? Solid waste generation, reduction? Loading, unloading, and handling of potentially dangerous materials and wastes? Communicating environmental policies and procedures to suppliers and contractors? Where appropriate, have the criteria for operating control limits been established? Has the installation identified appropriate contracts (including installation support agreements) in which to include EMS requirements? Have EMS requirements been incorporated into contracts? How does the installation ensure that contractors/tenants and suppliers are meeting defined responsibilities? What is your role within the EMS? How do you identify what contracts require the inclusion of EMS specific responsibilities/requirements? Do you have examples where EMS language 9/21/2010` Page 27 of 45

28 Env Program Managers/Cross Functional Team Shop Level has been incorporated into contracts? How do you ensure that contracts are not being released without some environmental considerations? Has the installation identified a way to categorically exclude certain types of contracts from environmental review? What guidance if any has come down from ACA regarding including EMS requirements into contracts? What operational controls have been put in place to help ensure that you achieve objectives and targets? What operational controls have been developed to help ensure that compliance is maintained? How do you identify who needs to have operational controls? How do you ensure that obsolete operational controls are removed from use? How do you notify users of any changes to the Operational Controls? What activities contribute to your significant aspect? Are operational controls in place? How do you identify when new activities are brought online that may require development of operational controls? How do you ensure that operational controls are functioning properly? What if any operational controls (SOPs) exist that instruct you on how to perform your job? How do you know that you have the most current version of the procedure? If a change is needed who do you notify? If a process changes or is added who do you notify? How often do you review the procedure? 9/21/2010` Page 28 of 45

29 How were you trained on what needs to be done? Are there any records to show that you were trained? Who maintains them? How are new employees trained on local procedures? Who provides this training and is it documented? Do you know what the installations significant aspects or objectives and targets are and how they relate to your job? U.S. Army-Hawaii Sustainable Environmental Management 9/21/2010` Page 29 of 45

30 Audit Criteria EMERGENCY PREPAREDNESS AND RESPONSE 14001:2004 The organization shall establish, implement and maintain procedures to identify potential emergency situation, and potential accidents that can have an impact(s) on the environment and how it will respond to them. The organization shall respond to actual emergency situations and accidents and prevent or mitigate associated adverse environmental impacts. The organization shall periodically review and, where necessary, revise its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations. The organization shall also test such procedures where practicable. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review Has the facility developed and implemented procedures for responding to accidents and emergencies, and preventing or mitigating the environmental impacts that may be caused by them? How are these procedures documented? Are they reviewed - and revised, wherever necessary - after any accidents? Has the facility compared its documented contingency plan and/or risk management program with the ISO requirements for these procedures (i.e., is there a system for reviewing and revising existing plans)? Have employees been trained on how to respond to accidents or emergency situations? Has the facility coordinated with emergency services such as medical, fire departments and hazardous material teams? Fire Chief What procedures have been developed to prevent and mitigate the environmental impact that may be associated with an accident or emergency situation? 9/21/2010` Page 30 of 45

31 Shop Level General population Who is responsible for reviewing/revising the facility s emergency preparedness procedures? How does the facility evaluate its emergency preparedness procedures? What procedures are in place to evaluate the effectiveness of the emergency preparedness procedures after an incident? How often are these procedures tested? Have you conducted after action reviews when there has been a test of the procedures or after an actual emergency situation has taken place? Can you provide examples of how recommendations have been incorporated into current procedures? Has the facility communicated to its employees the procedures for dealing with accidents and emergency situations? What training have you had to respond to emergency situations? What are the things that you should do (is this consistent with the procedure)? Do you participate in testing the emergency response procedures? Have you conducted after action review? What do you do if you notice an emergency situation? 9/21/2010` Page 31 of 45

32 Audit Criteria MONITORING AND MEASUREMENT 14001:2004 The organization shall establish, implement and maintain a procedure(s) to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant environment impact. The procedure shall include the documenting of information to monitor performance, applicable operational controls and conformity with the organization s environmental objectives and targets. The organization shall ensure that calibrated or verified monitoring and measurement equipment is used and maintained and shall retain associated records. Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review How is environmental performance regularly monitored? How have specific environmental performance indicators been established which relate to the organization s objectives and targets and what are they? (ISR/EQR?) How does the installation know what type of instrumentation requires calibration and the calibration frequency? What control processes are in place to regularly calibrate and sample measuring and monitoring equipment and systems? Have you established methods to calibrate monitoring equipment, making sure testing and monitoring equipment are working properly and the data is reliable? Have you established procedures and installed equipment to monitor the process characteristics that can have a significant environmental impact? Do the monitoring procedures enable the facility to measure its performance against its objectives/targets; are monitored indicators linked with the objectives? Are the monitoring strategies consistent with the environmental policy? 9/21/2010` Page 32 of 45

33 Env Program Managers/Cross Functional Team Shop Level What is monitored measured to show progress in achieving environmental targets and objectives? Who records this data? Where is it located? How often are they required to report the information? Does the information collected measure the proper parameters? Does the information being collected agree with performance indicators? How do you ensure that the data collected is reliable and accurate? What instrumentation requires calibration? What is the calibration frequency for those instruments? How often is this data reported to management? What forum is this done at? What data have you been asked to record? How often are you required to record it? How often to you provide a roll-up and to whom do you provide it? IF gauges are used as operational controls how often are they calibrated to verify they are functioning properly? Who maintains the calibration records? How do you know what needs to be calibrated? 9/21/2010` Page 33 of 45

34 Audit Criteria EVALUATION OF COMPLIANCE 14001: Consistent with its commitment to compliance, the organization shall establish, implement and maintain a procedure for periodically evaluating compliance with applicable legal requirements. The organization shall keep records of the results of the periodic evaluations The organization shall evaluate compliance with other requirements to which it subscribes. The organization may wish to combine the evaluation with the evaluation of legal compliance referred to in or to establish a separate procedure. The organization shall keep records of the results of the periodic evaluations. AR Checking and Corrective Action Environmental performance assessments and Environmental Management System audits a. General. (1) Garrison commanders (GCs) should maintain an inventory of compliance sites and activities with potential to impact the environment. (2) Audits conducted under the Environmental Performance Assessment System (EPAS) will include all operations and activities within the installation boundary (including operational ranges, and other training areas), or a representative sample of similar activity types, and will evaluate overall environmental program performance and conformance with ISO (3) Assessments will include tenant activities, outgrants, leases, and other activities under the purview of the Army. c. Internal assessments (1) Internal assessments will be conducted annually, at a minimum Questions that auditors may want to ask. Position Requirements Reference Results Comments/Interviewee EMSMR/Document Review Does the facility have implemented procedures for periodically evaluating compliance with applicable legal requirements? Does the facility have implemented procedures for periodically evaluating compliance with other requirements to which it subscribes? Are records of these evaluations kept? Who is responsible for performing compliance 9/21/2010` Page 34 of 45